One letter, eight places.

1. Duvall City Council and Planning Commission, into the record of the Title 14 amendments and the comprehensive plan update sent September 23, 2026
2. The Duvall City Clerk, as Public Records Officer (section 6 is a request under chapter 42.56 RCW) sent September 23, 2026
3. Washington Department of Commerce, Growth Management Services, during the state's 60-day review
4. The King County Executive
5. The King County Councilmember for District 3
6. The King County Growth Management Planning Council, for its November 18 meeting
7. The Snoqualmie Valley Record, as an open letter
8. City of Duvall Planning, as lead agency for the environmental (SEPA) consultation, due October 2

Subject: Duvall's housing capacity, the rent ceiling in draft chapter 14.47, the city's lot on Big Rock Road, and five things that would make the program produce homes

To the Duvall City Council and Planning Commission, and to the agencies copied below.

We are a household in the Snoqualmie Valley. We are not planners and nobody pays us. Over the past weeks we read the city's recordings, minutes, slides, memos and draft chapters, the consultant's capacity analysis, the state statutes, the county's parcel records, the federal income tables and the local rent listings, and we built a model that reproduces the arithmetic. The analysis and every source are published at dontbothellduvall.com, so that anyone can check it or correct it without attending a meeting. The model is published beside it as a spreadsheet.

We are asking for five things.

1. Publish the capacity by income level

The September 15 workshop slides give capacity by zone: 932 homes against a target of 890, a margin of 42. The test the appeal turns on is by income level, and that split is not published. Using the method in the December 2025 BERK analysis, we estimate the under-80%-of-median capacity at 665 to 719 homes against a need of 675, which is anywhere from 10 short to 44 over, depending on things only the city knows: how much of the commercial row counts, whether pipeline projects count as capacity, and which vacant public parcels are counted.

Please publish the August 2026 table by income level. If our estimate is wrong, the correction takes one spreadsheet and settles the central question in public.

2. Set the rental affordability level at 50% of median income, not 80%

State law sets 50% of county median family income as the level for rental units in an affordable housing incentive program (RCW 36.70A.540(2)(b)(i)). A higher level, to a maximum of 80%, is allowed only if the council, after a public hearing, finds that the higher level is needed to address local housing market conditions (RCW 36.70A.540(2)(b)(iii)). Draft DMC 14.47.030.C.1 uses 80% for all units, rentals included.

Here is why we believe that finding could not be made honestly on the current record. A two-bedroom at 80% of median may rent for about $2,425 before utilities. The valley's newest apartment building, Tolt 24 in Carnation (built 2021), lists two-bedrooms from $2,196, and the typical starting rent across 39 nearby buildings is about $2,300. A ceiling set above market rent restricts nothing, and the city would be spending public money on a label. The state's own auditors found this pattern statewide in 2019, when the legal "low-income" ceiling exceeded the typical market rent in at least 498 zip codes.

At 50% of median the restriction is real: about $546 a month below market on each restricted home.

3. Adopt the fee-waiver framework, and aim it where it buys the most

The City Administrator's memo of September 8 sets out how the council could waive fees for affordable housing: up to 80% of park and transportation impact fees with no backfill (DMC 14.58.030), utility connection fees under the 2023 statute (RCW 35.92.385), and building and permit fees once the code authorizes them. We support adopting that framework now, for income-restricted homes.

Our numbers say it is the best-value tool the city holds. Duvall's fees are about $33,000 per apartment and $59,000 per townhome (2026 schedule). Of the $33,000, about $14,400 is park and transportation impact fees, of which the 80% the memo describes, about $11,500, needs no backfill; the other $18,800 is utility connection charges, which can be waived but must be paid from other money. Counting all of it as a public cost, waiving the fees on homes restricted at 50% of median returns about $1.57 of rent reduction for every public dollar, against about $0.81 for the property tax exemption, and nothing at all at an 80% ceiling. So we ask that the waiver be tied to rents at 50 or 60% of median, secured by a recorded covenant, as in Everett's program.

4. Weigh the city's own land before committing it, and a proposed amendment

The promise. RCW 39.33.015 allows a city to transfer or lease surplus public property for affordable housing. The city has committed to this three times without doing it: comprehensive plan policy H-4.10 predates the 2023 Housing Action Plan; that plan's own review of H-4.10 records that the only action taken under it was rezoning surplus land from R4 to Public "due to outcry from adjacent neighbors"; the plan then proposed a ground-lease program as Action I.1, with an inventory of buildable public land as a short-term step; and the September 2026 draft comprehensive plan still carries H 4.10 as something to "analyze" and "explore." The draft plan's Capital Facilities element says the city already keeps a City Facility Assessment that lists "potential surplus facilities and properties." Please publish it.

The lot. The city owns Lot 409 of The Ridge at Big Rock Phase III: 2.09 acres at Big Rock Road and the Walden entrance. The 2008 Development Agreement required the developer to transfer "two unencumbered buildable acres ... to establish a city facility, unless otherwise agreed by the City," as a finished grade pad with installed utilities and improved street frontage (sections 15, 15(d), 15(e)(ii)). The lot was deeded to the city at no cost in December 2022, is vacant, and is appraised by the county at about $3 million. On August 19, 2025 the city's facilities consultants presented two options for "the Big Rock two-acre parcel," which they described as city-owned, vacant and at the south end of town: a police station there with city hall downtown, or both on that parcel; they also listed it among properties the city could "divest from to finance construction." Lot 409 is the only city parcel that fits that description. Before it is committed, we ask the council to weigh it for its best use, on the record.

The consultants told the council the police station at Depot Park is "at the end of life," with one point of egress, exposed computer equipment and cramped evidence and locker rooms, and should be replaced. We believe that need is overstated. The city renovated the station in 2023 and 2024 with federal recovery money (a new women's locker room, flooring, windows and paint); a year later the locker rooms are called too cramped. The problems named read as work for a remodel, for a department of 13 commissioned officers. And the consultants themselves warned that a new police station and city hall would cost more than the council can borrow without a vote. Before any new station is committed, please publish the police facility needs assessment, the cost of improving the existing station against the cost of a new one, and the city's plan for the Depot Park building if the police leave it.

We also ask whether improving the station where it stands was studied. The county's records show the station on a city-owned parcel of 6.68 acres at Depot Park (parcel 1326069118, zoned PF), more than three times the size of Lot 409. Its upper lot, on the Main Street side, is outside the flood zone on the federal flood map. The city also owns the land between the station and Main Street farther south: a 3.68-acre parcel beside the station (1326069211) and a 0.88-acre lot beside that one (1326069119), which reaches Main Street. A second way out could therefore run over city land alone, subject to the floodplain on parts of both parcels; the neighbouring business lots carry their own easements and, behind the church, a recorded wetland protection easement. One connection, over city land or by easement from a neighbour, would give the station a second way out; one modest auxiliary building, modular or container-type, on an enlarged upper lot would give secure room for computers, evidence and lockers. That is the most the named problems ask of the site, and it can be done at low cost and with little impact on the depot, the trail and the river. We recognize the consultants reported the department's preference for a site outside the downtown core, that the river side of the parcel likely falls under shoreline rules, and that the depot is historic. We ask the council to compare the cost of this option with the cost of a new station before choosing, and to have the department's space needs reviewed by an independent third party.

Lot 409 is the only vacant, buildable city lot in the proposed MU30 zone, where "residential density is a requirement for any new development" and a police facility is permitted only "as part of a mixed-use development that conforms to minimum residential density requirements" (draft DMC 14.20.020.B; Table 14.20.040.B, note 2). A station there would have to come with about 60 homes, and we doubt many families would choose to live above a police station. In our view Lot 409 should not become a police station.

The town's needs, as residents stated them at the September meetings, are homes people can afford, work close to home, infrastructure before density, and resilience when the river cuts the roads. The city's adopted policies already describe a building that answers them: "small-scale manufacturing, makers' space, flexible spaces ... foster entrepreneurship ... workforce training" (LU 7.1); affordable live/work studios with nonprofit partners (LU 7.5); public-private partnerships "related to the development of incubator spaces" (ED 1.12); and public land for affordable housing (H-4.10). A ground floor of shared workshops, a commercial kitchen and teaching space; permanently affordable homes above on a city ground lease; a solar roof and backup power so the south end has a place to gather when the roads close. That is the mix MU30 requires of any building there: homes above, a nonresidential share below. Programs exist for each piece, among them USDA Rural Development Community Facilities loans and grants, the Department of Commerce Building Communities Fund and Clean Energy grants, and the Washington Housing Trust Fund for the homes.

A ground lease also keeps the land public in the plainest sense. Under section 15(f) of the 2008 agreement, if the city sells the lot the developer holds a right of first refusal to re-acquire it.

Public land is the piece that makes the homes truly affordable:

A rent held at 30% of median costs about $123,000 over twelve years. Fees and the tax exemption alone come to about $97,000, which is not enough. With the land, it is. Public land closes that gap wherever it is worth about $760,000 an acre or more; Lot 409 is appraised at about twice that.

A proposed amendment. We ask that the following be entered into the record of the comprehensive plan update and the Title 14 amendments as proposed text, and considered before adoption:

1. Housing element, under H 4.10: "Before siting a single-purpose city facility on city-owned land in a mixed-use zone, evaluate the land for a mixed-use civic building that combines permanently affordable housing with makers' space, workforce training or community resilience uses, under a ground lease consistent with RCW 39.33.015."
2. Draft DMC 14.20, Table 14.20.040.B: permit specialty light industrial and manufacturing, or a defined shared workshop use, in MU30 as part of a mixed-use development, as the draft already does in MU20; and state how note 2 applies to governmental services.

And, because RCW 36.70A.130(2)(a)(iv) allows the capital facilities element to be amended together with the budget, we ask that the element as amended with the 2027-2028 budget not commit Lot 409 to a single-purpose building before this evaluation, and that the City Facility Assessment be published with it.

5. Do not spend the housing money on administration before the program produces anything

On September 15 the council discussed paying roughly $36,000 a year to an agency to administer affordable units, or adding about half a staff position. Before that is committed, please ask for the cost per home produced for each option, including a fee waiver and a public-land lease. Our estimates are published; we would rather the city's own numbers replaced them.

6. Public records request (chapter 42.56 RCW)

To the City Clerk as Public Records Officer, please treat this section as a request for:

1. the spreadsheet or workbook behind the September 15 capacity slides, including capacity by income level for both the December 2025 and August 2026 analyses, and a list of the parcels counted, including any city-owned parcels;
2. documentation of which projects are counted as "pipeline" in the August 2026 figures, and whether pipeline units count as capacity;
3. the source and calculation for the figure of 780 units built 2020 to 2024 used in the December 2025 BERK analysis (the state's own count for that period is 380 completed, and the city's plan appendix uses 433);
4. the city's displacement risk analysis for the housing element, and any anti-displacement measures under consideration;
5. any contract, task order or invoice for the December 2025 BERK analysis;
6. the City Facility Assessment, including its list of potential surplus facilities and properties;
7. the civic campus site selection study by Makers Architecture and Urban Design: the slides presented on August 19, 2025, the community survey and its results, the final analysis summary report, any cost estimates, any police facility needs assessment, any comparison of the cost of improving the existing police station with the cost of a new one, any evaluation of expanding on the Depot Park parcel (1326069118) or of a second access to it, and any plan for the Depot Park building;
8. any record giving the parcel number of "the Big Rock two-acre parcel" named in that study, and any record of its intended use;
9. the First Amendment (June 6, 2017) to the 2008 Development Agreement with CamWest, and any later amendment or correspondence concerning the City Property under section 15 of that agreement;
10. any communication from King County in 2025 or 2026 stating that the revised land capacity analysis did not require annexation.

Electronic copies by email are preferred.

7. Three questions for the record

On January 6, 2026 (city recording, about 3 hours 50 minutes) staff advised the council that, apart from how zoning blends between areas, the city did not need to change anything below R20. On September 1, 2026 (city recording, about 20 and 23 minutes), asked whether any capacity was still optional, staff answered that "we don't have any fat to trim" and "there ain't no fat left in the map." Please state what changed, and how much of the August 2026 capacity in R4 through R12 and in accessory dwelling units counts toward the 0 to 80% requirement.

On the authority for chapter 14.47: please state in the adopting ordinance which statute the program is adopted under, and, if rentals are set above 50% of median, include the hearing and the written finding that RCW 36.70A.540(2)(b)(iii) requires.

On Lot 409: please state whether the city intends its own facilities to meet the MU30 residential-density requirement, to be exempt from it, or to be sited on land rezoned for them; and whether the city reads section 15 of the 2008 agreement to allow a long-term ground lease of the lot. And if the police leave Depot Park, what the city plans for the building it renovated for them in 2023 and 2024.

8. To the agencies copied

To the City as SEPA lead agency: for the pre-threshold consultation on CPU24-01 and CA26-005, we ask that the threshold determination consider the land use, housing and public services questions above, including where city facilities are sited in MU30 and what happens to the Depot Park building.

To the Department of Commerce: the rental level, the absence of a published capacity table by income level, and the unexercised public-land policies are offered as comment during the 60-day review under RCW 36.70A.106.

To King County: the county assigned this target and reviewed the capacity analysis that unlocked the work plan; on January 6 city staff reported that the county had identified that the revised analysis did not require annexation, so the capacity was found by rezoning inside the town. The city's own adopted plan (policy LU 9.2) calls for working with the county to move growth-boundary land into a South UGA "to meet growth targets and accommodate deeply affordable housing," and says the city will apply "when the County is ready to process requests." Meanwhile county Conservation Futures money moves readily for park and conservation land at the town's edge. We ask the county to say when it will accept urban growth area adjustment requests, and we ask the city to commit to filing the one LU 9.2 describes. We also ask the county to invite a reconciliation request from Duvall and consider it on the record, as it did for the Black Diamond area in November 2025 (Motion 25-3), and to recognise that the 409 homes the plan assigns below 30% of median cannot be produced by any city instrument alone. The county also owns 75 acres of farmland at the edge of Duvall, bought with public money in 2020 and unused since. A county that asks a small town to find room it does not have might begin by putting its own idle ground to work. We should say plainly that we have published a proposal to lease that farm for a community farming cooperative and food hub, under a compatible-use lease and no sale; it is disclosed at dontbothellduvall.com/who-publishes-this.html, it adds nothing to Duvall's housing count, and nothing in it moves before the county rules on feasibility and compatibility.

9. One more thing, plainly

Everything above was produced by people with other jobs, from public records, and we are publishing it for free.

We are not asking this body for a delay, and nothing in this letter is a bid. What we are asking is that the public's own numbers be published in a form a resident can open, that the public's own land be weighed for its best use in public, and that public money go where it buys a home rather than a label.

For the record: we do paid consulting and computing work in this valley, disclosed at dontbothellduvall.com/who-publishes-this.html. We take no paid work from the city or the county on any matter in this letter, and nothing here is a bid.

If any figure here is wrong, tell us and we will correct it publicly within a day. The analysis and the sources are at dontbothellduvall.com.

Respectfully,

One valley household and its collaborators

The analysis behind every figure in this letter is the article, with its sources, and the numbers.